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Genuineness of a political contribution, rather than banking-channel payment or a donation receipt, determines eligibility for deduction under section 80GGC. Admissions by political-party office bearers, search material, banking patterns and statutory non-compliance may establish an accommodation-entry arrangement; in that setting, receipts and bank statements may not rebut the evidence. The transaction must be assessed on human probabilities, surrounding circumstances and preponderance of probabilities. On these facts, the claimed deduction was disallowed. A challenge to initiation of penalty proceedings under section 270A was treated as premature.
Genuineness of a political contribution, rather than banking-channel payment or a donation receipt, determines eligibility for deduction under section 80GGC. Admissions by political-party office bearers, search material, banking patterns and statutory non-compliance may establish an accommodation-entry arrangement; in that setting, receipts and bank statements may not rebut the evidence. The transaction must be assessed on human probabilities, surrounding circumstances and preponderance of probabilities. On these facts, the claimed deduction was disallowed. A challenge to initiation of penalty proceedings under section 270A was treated as premature.
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